INDUSTRIAL ACCELERATOR ACT · PROPOSED 4 MARCH 2026
ARE YOUR BATTERY SYSTEMS EU-READY?
The European Commission has proposed EU-origin requirements for certain publicly supported battery-storage projects. The Commission's draft Industrial Accelerator Act would tie public procurement, subsidies, and renewable-energy auctions to EU-origin content for battery storage (including, above 1 MWh) a battery management system meeting the applicable Union-origin requirements. Here's what's proposed, what's still being negotiated, and how to get ahead of it.
THE PROPOSAL
SUMMARY
On 4 March 2026, the European Commission published a draft regulation intended to rebuild manufacturing capacity in strategic sectors (energy-intensive industry, net-zero technologies, and automotive) and reduce the EU's dependence on non-EU suppliers for equipment like batteries and battery storage.
The mechanism is different from a straightforward import ban: the Act would condition access to public money (public procurement, public support schemes, and renewable-energy auctions) on products meeting EU-origin content requirements. For battery energy storage systems (BESS), that requirement extends specifically to the battery management system.
This is still a proposal, not law. The European Parliament and the Council of the EU both have to negotiate and formally adopt the text before any of it takes effect, and the thresholds described below could still change during that process.
WHAT IS AFFECTED
THE BMS IS NAMED IN THE FIRST STAGE. BEFORE THE CELLS.
A phased Union-origin framework is proposed for certain publicly supported BESS projects.
Stage 1 – one year after entry into force: BESS covered by the relevant public procurement, auction or support-scheme rules must be of Union origin. For projects with storage capacity above 1 MWh, the battery management system must additionally be of Union origin.
Stage 2 – three years after entry into force: BESS must continue to be of Union origin, and the battery cells, the BMS and at least one further specific main component must also be of Union origin. The proposal sets no capacity threshold for this stage, so it would in principle apply to smaller systems as well.
ORIGIN BECOMES AN ENTRY TICKET, NOT A TIEBREAKER.
Union origin moves from a scoring bonus to a pre-qualification or award criterion.
AUCTIONS GET WIDER AND STRICTER
Non-price criteria rise from at least 30% or 6 GW to at least 40% or 8 GW of auctioned volume per member state per year. Cybersecurity pre-qualification extends to the full volume, up from 30%.
→ The Industrial Accelerator Act is still a proposal, and thresholds will be set in delegated acts. The direction of travel is not in doubt: on both sides of the Atlantic, the provenance of your BMS has become a commercial variable.
THE IMPACT ON YOUR SYSTEMS
YOU BUILD OR OPERATE STORAGE?
PUBLIC FUNDING WILL NEED TRACEABLE EU PROVENANCE
Auctions, subsidies, and procurement for BESS above 1 MWh would require a documented EU-made BMS once Stage 1 applies.
A NON-EU BMS COULD AFFECT ELIGIBILITY IN THE FUTURE
If the proposal is adopted as drafted, a BESS with a non-EU BMS might no longer qualify for certain public funding, auctions or procurement, even if the rest of the system is EU-assembled.
REQUALIFICATION TAKES LEAD TIME
Qualifying a new BMS supplier — integration, safety certification, field validation — isn't instant. Starting before the clock runs is the safer path.
THE BMS-NECESSITY CARVE-OUT IS STILL OPEN
Don't assume your chemistry or system size is exempt until the final text and Annex II language are settled.
ALREADY IN FORCE · REGULATION (EU) 2024/2847
THE CYBER RESILIENCE ACT ADDS A CYBERSECURITY BAR OF ITS OWN.
Unlike the Industrial Accelerator Act, this one isn't a proposal — the Cyber Resilience Act (CRA) entered into force on 10 December 2024 and applies horizontally to virtually every product with digital elements sold in the EU. A battery management system will generally fall within the CRA’s scope where it is made available on the EU market as a product with digital elements and no specific exclusion applies. It's a separate legal instrument from the IAA: the IAA is about where a BMS is made, the CRA is about how securely it's built and maintained.
The IAA and the CRA reinforce each other rather than compete: an EU-made BMS satisfies the IAA's origin test, and building it to CRA's secure-by-design and reporting standards is what keeps it eligible once cybersecurity requirements tighten too.
10 DEC 2024
CRA enters into force
The clock starts on a set of phased obligations rather than a single compliance date.
11 JUN 2026
Conformity assessment bodies come online
Notified bodies begin certifying products against CRA requirements.
11 SEP 2026 · ALREADY ACTIVE
Vulnerability & incident reporting becomes mandatory
Manufacturers must report actively exploited vulnerabilities and severe incidents to ENISA, with an initial 24-hour early warning. This obligation is already live.
11 DEC 2027
Full compliance and CE marking
Secure-by-design requirements, SBOMs, support-period commitments, and CE marking become mandatory for products placed on the EU market.
Vulnerability and serious-incident reporting is already mandatory today for any BMS you place on the EU market as a stand-alone product with digital elements.
Full compliance — secure-by-design practices, a software bill of materials, defined support periods, CE marking — becomes mandatory on 11 December 2027, but auditing your own BMS supplier's readiness is worth starting well before then.
Trade body Energy Storage Europe published a report this month calling for BMS, power conversion systems, and energy management systems to be reclassified as "critical" products under the CRA — moving them from self-assessment to mandatory third-party conformity assessment, on the grounds that they're the primary cyber attack surface of a BESS. That reclassification hasn't happened yet, but it signals where the bar is heading.
THE SOLUTION
THE ADVANTAGE OF BEING AHEAD
Engineered in Germany and manufactured in Europe, built to drop into existing battery racks up to 1500 V: Munich Electrifications Drop-In stationary storage BMS.
DROP-IN REPLACEMENT · INSTALLED AND ORDERED FLEETS
OUR BMS IS EU-MADE TODAY, NOT EVENTUALLY
Munich Electrification's Smart Battery Sensor and Cell Monitoring Board platform for stationary storage is engineered in Munich, Germany and manufactured in Europe. A natively EU-origin BMS, designed with the proposed Union-origin requirements for publicly funded BESS projects in mind.
Up to 1500 V:
Sized for utility-scale BESS strings.
ISO 13849:
ISO 13849-1 Kat. 2 / PL d (CSA).
UL 5500 conformity:
Certified to UL 5500.
CAN & Ethernet:
Fits existing plant control integrations.
Off-the-shelf or fully customized per cell format.
Up to 64-channel CMB:
Hardware and software developed in-house in Germany. Made in the EU.
Engineered in Munich:
SELLING IN THE US TOO?
DROP-IN REPLACEMENT · INSTALLED AND ORDERED FLEETS
Our BMS gives you control over firmware, update channels and remote access, the areas Executive Order 14421 focuses on.
DISCLAIMER
This page summarizes The Industrial Accelerator Act (a legislative proposal that may change materially before adoption) for general informational purposes. Consult a qualified counsel to assess your own compliance position.
Primary sources: Industrial Accelerator Act, full text · European Commission
ORDER 14421